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Payment Services Act 2019: Singapore’s Payment Licensing Law Explained
The Payment Services Act is Singapore’s payment licensing law. Learn who needs a license, how SPI and MPI thresholds work, and what the 2024 changes mean.
The Payment Services Act 2019 is Singapore’s single licensing law for payment services. Parliament passed it on 14 January 2019, and it took effect on 28 January 2020. If your business moves money, issues e-money, or touches crypto in Singapore, this law decides whether you need a license, which type, and what compliance costs to budget.
The Act regulates seven payment services, from account issuance and money transfers to digital payment token (crypto) services. One regulator, the Monetary Authority of Singapore (MAS), licenses and supervises every provider.
The rules changed recently. The Payment Services (Amendment) Act 2021 took effect on 4 April 2024. It widened the definition of regulated activities and raised the requirements for crypto firms. In 2026 the law works like this: the three license types, which one fits your business, and how to start.
What is the Payment Services Act?
The Payment Services Act is the primary law for payment licensing in Singapore. It sets out who must hold a license, the license types, and the conduct and prudential rules licensees must follow. MAS is both the regulator and the licensing authority.
The Act replaced two older regimes: the Money-changing and Remittance Businesses Act (MCRBA) and the Payment and Settlement Systems (Oversight) Act (PSOA). Money-changers, remitters, and e-money issuers once came under separate rules. One statute now covers payment services, payment systems, and settlement institutions.
The Act also covers designated payment systems. MAS designates systems that are critical to Singapore’s financial infrastructure and supervises the entities that run them.
One naming note: Japan has a separate law that is also called the Payment Services Act. For Singapore rules, search “payment services act Singapore” or read the MAS page directly.
Who needs a license: the seven regulated payment services
The Act regulates seven payment services. If you carry on a business providing any of them in Singapore, you need a license unless an exemption applies.
| Service | What it covers |
| Account issuance | E-wallets, stored-value cards, and the services needed to operate such accounts |
| Domestic money transfer | Local fund transfers, payment gateways, payment kiosks |
| Cross-border money transfer | Inbound and outbound remittance; arranging transfers between two other countries |
| Merchant acquisition | Accepting and processing payment transactions for merchants |
| E-money issuance | Issuing e-money that customers use for payment or transfer |
| Digital payment token service | Buying, selling, or exchanging crypto; transmitting DPTs; custody of DPTs |
| Money-changing | Buying and selling foreign currency notes |
Two services have wide definitions. Cross-border money transfer includes arranging transfers between two other countries even when no monies pass through Singapore. That change took effect in 2024. Digital payment token service includes custody, and the facilitation of buying, selling, or transmitting tokens, with or without possession of the tokens.
The three license types: standard vs major vs money-changing
The Act creates three license types. The standard payment institution (SPI) and the major payment institution (MPI) split on volume. The money-changing license covers one service only.
Apply for an SPI license when your volumes stay at or below these thresholds:
- Average monthly transaction value of SGD 3 million or less for any one payment service.
- Average monthly transaction value of SGD 6 million or less in total across two or more payment services.
- Average daily outstanding e-money of SGD 5 million or less.
The thresholds exclude e-money account issuance and money-changing services.
Apply for an MPI license when you exceed any of these thresholds. An MPI faces no transaction-volume limits.
Apply for a money-changing license when the business provides money-changing service only.
| License | When it fits | Base capital | Other financial duties |
| Standard payment institution (SPI) | At or below the thresholds | SGD 100,000 | Lighter ongoing duties |
| Major payment institution (MPI) | Above the thresholds | SGD 250,000 | Security deposit of SGD 100,000 or SGD 200,000; safeguarding duties |
| Money-changing licensee | Money-changing service only | No prescribed minimum | Ownership and residency conditions |
An applicant must be a Singapore-incorporated company or a Singapore branch of a foreign company. You need a permanent place of business or a registered office where the books and records are kept. You need at least one executive director who is a Singapore citizen or permanent resident, or one executive director on an Employment Pass plus another director who is a citizen or permanent resident. Money-changing licensees follow ownership rules: Singapore citizens, or companies that are majority Singapore-owned.
Base capital is a floor, not the whole test. MAS expects a capital buffer above the minimum, sized to the scale and risk of the business.
MPIs must place a security deposit with MAS, in cash or as a bank guarantee. The amount is SGD 100,000 when the average monthly transaction value for each payment service stays at SGD 6 million or less, and SGD 200,000 otherwise.
What compliance costs
Budget for five cost blocks: capital, safeguarding, AML/CFT, conduct, and audit.
Capital. Base capital as above, plus a buffer that fits your volumes.
Safeguarding. Major payment institutions that receive customer money for transfers, merchant acquisition, or e-money issuance must safeguard it. Standard payment institutions are not subject to this duty. Customer monies go into a trust account with a safeguarding institution, or the MPI obtains an undertaking or a guarantee from that institution. The safeguard must be in place by the end of the next business day after the money is received. For e-money, the duty applies from the moment the money is received in exchange for the e-money. Digital payment token providers must hold customer assets in a segregated trust account under the 2024 rules.
AML/CFT. MAS prescribes anti-money laundering and countering the financing of terrorism duties through notices under the Act. Customer due diligence, record keeping, and suspicious transaction reporting are core duties. The board carries the accountability.
Conduct. The Act and its notices set conduct rules. One example: a domestic money transfer must reach the beneficiary within three business days, and a cross-border transfer within seven, unless merchants agree otherwise in writing.
Audit. Licensees must appoint an auditor at their own expense each year. The audit covers the accounts and compliance with the Act and the regulations.
Compliance arrangements must fit the nature, scale, and complexity of the business. MAS tests your plans for compliance, technology risk, and audit before it grants a license. If you offer online financial services, you must run a penetration test and fix the high-risk findings before MAS issues the license.
What the 2024 amendments changed
The Payment Services (Amendment) Act 2021 commenced on 4 April 2024. It is why the 2019 Act matters differently in 2026.
The amendment did three things:
- It broadened the digital payment token service. Custody of DPTs, and the facilitation of DPT transmission or exchange, are regulated even when the provider never holds the monies or the tokens.
- It broadened cross-border money transfer. Arranging transfers between two other countries is regulated even when no monies are accepted or received in Singapore.
- It added user protection duties for DPT providers. Customer assets must be segregated and placed in a trust account, with books, records, and systems to protect them. The safeguarding rules took effect six months after the appointed day, from October 2024.
Firms already doing the newly regulated activities received transitional cover. They had to notify MAS by 4 May 2024, apply for a license by 4 October 2024, and file an auditor attestation report by 4 January 2025. Those windows are closed. New entrants get no transitional cover.
In May 2026, MAS revoked the major payment institution license of Bsquared Technology (Bsquared), a digital payment token service provider. The decision shows how actively MAS enforces the regime.
The Payment Services Act and crypto
Digital payment token services were in scope from day one. Exchanges, OTC desks, and other dealers in digital payment tokens have needed a license since 28 January 2020. Custody and brokering of tokens fell into scope only with the 2024 amendment. It also closed the gap on non-custodial facilitation of token transactions.
Stablecoins sit inside this regime. MAS treats stablecoins as digital payment tokens; compliant issuers will be able to earn a “MAS-regulated stablecoin” label once the framework’s legislation is in force.
In August 2023, MAS finalized its single-currency stablecoin (SCS) framework. It applies to stablecoins pegged to the Singapore dollar or a G10 currency and issued in Singapore. Issuers that meet the conditions can have their tokens labeled “MAS-regulated stablecoins”. The conditions cover reserve backing of at least 100% in cash and liquid assets, minimum base capital, redemption at par within five business days, and disclosure.
The framework is not yet in force. MAS said in November 2025 it was ready to begin drafting the implementing legislation; as of August 2026 it has not been introduced. Until it lands, stablecoin issuance counts as a digital payment token service under the existing regime.
Founders comparing regions will notice a gap. The EU solved the same problem sooner: MiCA’s rules for asset-referenced and e-money tokens are in force, and our MiCA license list covers the EU license types for a parallel structure.
Exemptions, transitional relief, and the cost of operating unlicensed
Exemptions exist, but most are temporary. Firms already operating when the Act took effect ran under time-limited transitional exemptions: 12 months for most services (until 28 January 2021) and six months for digital payment token services (until 28 July 2020), while a license application stayed pending. The 2024 amendment created its own transitional window for the newly regulated activities, described above.
Operating without a license is an offense under section 5 of the Act. An individual faces a fine of up to SGD 125,000, imprisonment of up to three years, or both, plus daily fines while the offense continues. A company faces a fine of up to SGD 250,000 plus daily fines. MAS can direct unlicensed operators to stop, and it can act against directors.
MAS publishes the licensed population in its Financial Institutions Directory. If a counterparty claims to be regulated, check the directory before you rely on it.
How to start
Follow this sequence:
- Confirm the activity is regulated. Compare your services with the seven regulated services, and use MAS’s licensing self-check tools.
- Pick the license type. Estimate monthly transaction value, total across services, and daily e-money float. Compare the figures with the SPI thresholds.
- Build the entity and the compliance program. Incorporate in Singapore or open a branch, appoint directors, and prepare base capital, safeguarding, AML/CFT, and technology risk controls.
- Apply to MAS before you start. There is no grace period for new entrants. MAS assesses fitness and propriety, competency, compliance arrangements, and financial position.
- Budget for the ongoing load. Annual audit, capital buffers, compliance staff, and reporting are recurring costs, not one-off fees.
Singapore rewards preparation. LegalBison builds the regulatory architecture and licensing for payment, crypto, and FinTech companies across jurisdictions, including MAS licensing for Singapore. We confirm the license class, prepare the application, and set up the compliance program through a single point of contact. Schedule a free consultation to map your route into the Payment Services Act regime.
MAS publishes the official Guide to the Payment Services Act 2019, plus licensing guidelines, notices, and FAQs. Start there for the fine print.
